G.R. No. 197645 APRIL 4, 2018
CARLOS JAY ADLAWAN, Petitioner, vs. PEOPLE OF THE PHILIPPINES, Respondent.

FACTS

Petitioner Carlos Jay Adlawan was charged with Frustrated Murder and Attempted Robbery. The prosecution evidence established that on February 18, 2004, petitioner, who was jobless and had a contentious relationship with his stepmother, private complainant Georgia Adlawan, confronted her at their home demanding money. An argument ensued, after which petitioner attacked Georgia with a katana (Japanese sword), inflicting multiple hack wounds on her neck, stomach, shoulders, and back. Georgia managed to escape and was hospitalized. The attending physician testified that the neck wound would have been fatal without timely medical intervention. The prosecution’s version was corroborated by an eyewitness, the family driver. The defense presented only the houseboy, Cornelio Selin, who testified that Georgia’s injuries resulted from a fall and that he did not see petitioner armed or hacking her. The Regional Trial Court convicted petitioner of Frustrated Homicide, a decision affirmed by the Court of Appeals.

ISSUE

Whether the Court of Appeals erred in affirming petitioner’s conviction for Frustrated Homicide despite the alleged weakness of the prosecution’s evidence and the defense’s version of events.

RULING

The Supreme Court denied the petition and affirmed the conviction. The Court emphasized that factual findings of the trial court, especially when affirmed by the CA, are generally binding and conclusive. It found no reason to deviate from this rule, as the trial court’s assessment of witness credibility was sound. The prosecution successfully proved all elements of frustrated homicide: a criminal act of killing performed by the offender, which did not produce homicide due to a cause independent of the offender’s will—here, the timely medical intervention that prevented Georgia’s death. The positive, clear, and consistent testimonies of Georgia and the corroborating eyewitness prevailed over the solitary and uncorroborated denial of the defense witness. The Court also ruled that the alleged illegality of the warrantless search and seizure of the weapons from petitioner’s room was irrelevant to the conviction, as the weapons were not indispensable to proving the crime given the overwhelming direct eyewitness testimony and medical evidence. The Affidavit of Recantation executed by Georgia was given no weight, as recantations are notoriously unreliable and can be easily secured. Thus, petitioner’s guilt was proven beyond reasonable doubt.